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FDIC Federal Register Citations

BANK OF TERRELL

March 22, 2004

Robert E. Feldman, Executive Secretary
ATTN. Comments
Federal Deposit Insurance Corporation
550 17th Street NW
Washington, DC 20429

Re: 12 CFR Part 345
Proposed Revisions to the Community Reinvestment Act Regulations

Dear Mr. Feldman:

This letter is to express our bank's support to the federal regulatory agencies' proposed amendment to CRA to increase the asset size of what is considered to be "small institutions" and to eliminate any consideration of whether the small institution is owned by a holding company. These proposed changes are overdue and will greatly lessen current and future regulatory burdens.

The current "small institutions" assessment test is satisfactory for smaller banks (we are a $100 million bank, part of a 3 bank $210 billion holding company). All three banks have always received satisfactory or better marks on CRA ratings and continue to strive to provide financial services to all of our communities. When the small institution test was enacted in 1995, it greatly relieved unnecessary regulatory burden and paperwork. All three banks are located in small, rural communities with town populations of less than 5,000 people. It simply would not be prudent banking nor business practice to not service our community to the greatest extent possible. Due mainly to inflation, it is not unreasonable to think that some time in the future our bank could reach $250 million in assets. Certainly, there are many banks in our similar situation who do an excellent job of servicing their communities financial needs and should not be penalized because they have grown due to increased "costs of living." Please do consider raising the current asset size to $500 million and include future clauses to provide for additional raises in asset size should the cost of living warrant increases in the future (because it most likely will).

As you can see from the numbers above, our holding company, the Georgia Community Bancorp, is approaching the holding company asset limit. Although all 3 of the banks in our holding company have similar market areas and service each one to the best of their extent, each bank does operate independently of one another. Trying to coordinate a holding company wide large bank assessment test would be very difficult, time consuming and expensive. In the end, it would not provide any additional useful information to regulators and only serve to increase regulatory burden. $250 billion is not considered a large holding company by today's standards. Increasing this limit to at least $500 billion will continue to streamline bank examinations.

In conclusion, when CRA was revised in 1995, it greatly reduced regulatory "red-tape". However, the asset sizes used then did not take into consideration normal growth of even truly small community banks and holding companies like ours. We strive everyday to meet the financial needs of our community; please take this into consideration when making your decision.

Sincerely

Lucie Beeley
Bank of Terrell, Dawson, Georgia (229) 995-4461


Last Updated 03/26/2004 regs@fdic.gov

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